International Shoe Co. v. Washington
International Shoe Co. v. Washington | |
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Case history | |
Prior | Special appearance by appellant in Washington state court as defendant in lower court; appellant moved to set aside order on grounds of lack of personal jurisdiction; tribunal denied motion; state Superior Court affirmed; state Supreme Court affirmed |
Holding | |
Suit cannot be brought against an individual unless they have minimum contacts with the forum state, and such lawsuit does not offend traditional notions of fair play and substantial justice. | |
Court membership | |
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Case opinions | |
Majority | Stone, joined by Reed, Frankfurter, Douglas, Murphy, Rutledge, Burton |
Concurrence | Black |
Jackson took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. Amendment XIV; 26 U.S.C. § 1606; Washington Unemployment Compensation Act |
International Shoe Co. v. Washington, 326 U.S. 310 (1945), was a
Facts
The
Procedural history
International Shoe Co. did not pay the tax at issue in this case, so the state effected service of process on one of their salesmen with a notice of assessment. Washington also sent a letter by registered mail to their place of business in Missouri. International Shoe made a special appearance before the office of unemployment to dispute the state's jurisdiction over it as a corporate "person." However, the trial court ruled that it had personal jurisdiction over the defendant corporation. This ruling was upheld in the appeal tribunal, the Superior Court, and the Supreme Court of Washington. International Shoe Co. then appealed to the U.S. Supreme Court.
Ruling
The issue involved a determination of the level of connection that must exist between a non-resident corporation and a state in order for that corporation to be sued within that state. The Supreme Court, in an opinion by Chief Justice
Analysis
A growing body of Supreme Court precedent and incremental statutory and common law doctrines related to personal jurisdiction had been evolving over a period of several decades from the late 19th century through the early 20th century, and the Supreme Court therefore could have upheld jurisdiction over defendant corporation. Initially the courts followed a strict interpretation of territorial jurisdiction, where states only had power over property or defendants who were actually present in the state (excepting corporations or residents). Defendants wishing to avoid claims could abscond to other jurisdictions without fear of suit.
As the doctrine of personal jurisdiction evolved with additional cases directed to related subject matter, the Supreme Court expanded jurisdiction to anyone who tacitly "consented" to jurisdiction (in that case, a defendant consented to jurisdiction by merely driving on a Massachusetts state highway). These doctrines were built upon the expanding legal fiction of "presence" within the forum state or the defendant's commission of an act or failure to act within the forum state. (A "forum state" means the state in whose courts a case is being litigated.)
In International Shoe, the Court's majority chose to create a new doctrine, while still adhering to a "presence" rationale. The basic formulation is: a state may exercise personal jurisdiction over an out-of-state defendant, so long as that defendant has "sufficient minimum contacts" with the forum state, from which the complaint arises, such that the exercise of jurisdiction "will not offend traditional notions of fair play and substantial justice . . ." See 326 U.S. 310 (1940).
The court broke down the types of contact that a defendant can have with a state into "casual" contact and "systematic and continuous" contact. In cases with only casual contact, the claim must be related to the contact in order for the state to have jurisdiction. Casual contact is not a basis for bringing unrelated claims. Systematic and continuous contact allows for both claims related to the contact and unrelated claims.
Legal legacy
It was and remains a broad doctrine. It eventually allowed states to create "long arm" statutes and responded to the actualities of the national market of the United States. Defendants had often avoided legal responsibilities by "scampering" from the state of occurrence and not being available for service of process. This case changed that to some extent, though the "traditional notions of fair play and substantial justice" are drawn from the Due Process Clause of the Fourteenth Amendment and Aristotle's[citation needed] notions of justice. The doctrine of International Shoe is broad, but the Court has recognized that it has limits, nevertheless.
See also
- List of United States Supreme Court cases, volume 326
- List of United States Supreme Court cases
- Pennoyer v. Neff
- Calder v. Jones
References
External links
- Works related to International Shoe Company v. Washington at Wikisource
- Text of International Shoe v. Washington, 326 U.S. 310 (1945) is available from: Findlaw Justia Library of Congress Lawlio
- International Shoe Co. v. Washington Case Brief at Lawnix.com